For supply of a large commercial quantity of MDMA (3.1kg, more than six times the threshold), where the offender's role was substantial but not that of a principal, an appropriate starting point before discounts is 12 years imprisonment. A discount of 20% is appropriate for an early guilty plea at the Local Court where the trial would have involved some complexity (foreign language intercepts) but the case was otherwise strong. Discounts for assistance should be applied sequentially to the post-plea figure, not simply added to the plea discount. Incarceration in the Custodial Witness Protection Program can constitute special circumstances, but the non-parole period should not fall below three-quarters of the total term for gross offending.
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